Conducting depositions abroad by written questions can save significant time and money when costs of traveling in person or taking a deposition by videoconference just don’t make sense from a cost perspective. If you decide to take a deposition by written questions, it is helpful to submit the written questions and opposing counsel’s objections, if any, prior to the deposition date so the court reporter can properly prepare. While the court reporter is often responsible for reading the questions and objections, if you decide to videotape the deposition, you may want to consider having the videographer read the questions so that the reporter can focus on taking down the record. This will also keep the deposition moving along at a reasonable pace.
Your on-the-ground court reporting team will ensure that any exhibits are pre-printed, bound, and brought to the deposition before the deposition starts, and the court reporter or videographer can present the exhibits as appropriate during the proceedings. At the conclusion of the deposition, rather than having the exhibits shipped back to the United States, the court reporter and videographer team can arrange to have them picked up and shredded at a secure facility.
Your court reporting team can also coordinate details on the ground, serving as the point of contact at the deposition location, effectively assuming concierge duties relating to local logistics, administrative or technical needs.
For more information on depositions taken abroad by written questions, please contact Planet Depos at 888-433-3767 or international@planetdepos.com.